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The Brazilian Sugarcane Industry Association (UNICA) welcomes the
opportunity to provide specific comments on California’s proposed
Low Carbon Fuel Standard (LCFS). The attached letter expands on our
previous correspondence regarding lifecycle calculations of
sugarcane ethanol and includes a number of specific recommendations
concerning the calculations of indirect land use change.  

We ask that the attached letter and all of its references be fully
considered by the California Air Resources Board (CARB) and staff
prior to approval of the regulation. The letter is structured as
follows: (I) Introduction of UNICA as having a direct and
significant interest in this rulemaking; (II) Comments and
recommended changes to life cycle assessment inputs and
assumptions; (III) Comments and recommended changes to land use
change calculations; and, (IV) Conclusions.